Allowing the appeal of the asseee the Tribunal held that ; Interest paid to head office abroad and income received on account of interest from Indian branches , Indian branches are not required to deduct tax at source . ( AY. 2005 -06)
Bank of Tokyo-Mitsubishi, UFJ Ltd. v. DCIT (2018) 61 ITR 272 (Delhi) (Trib)
S.40(a)(ia):Amounts not deductible – Deduction at source – Interest paid to head office abroad — Income received on account of interest from Indian branches — Indian Branches are not required to deduct tax at source [ S. 195 ]